Advocacy Comments on CPSC’s Proposed Residential Gas Furnace and Boiler Rule

On October 25, 2023, the Consumer Product Safety Commission (CPSC) published a proposed rule that would require all residential gas furnaces and boilers to, either directly or indirectly, continuously monitor the concentration of carbon monoxide (CO) produced during the combustion process. The gas furnace or boiler would also be required to incorporate a shutdown or modulation mechanism that would respond to specified CO concentration conditions. On January 24, 2024, the Office of Advocacy (Advocacy) filed a comment letter, Docket No. CPSC–2019–0020; Safety Standard for Residential Gas Furnaces and Boilers (PDF, 223 KB) recommending that CPSC publish a supplemental initial regulatory flexibility analysis (IRFA) and supplemental cost and benefit analysis.

Advocacy advised that:

  • Consumer safety is a top priority for small furnace and boiler manufacturers. However, CPSC’s proposed rule understates its costs. It is also unclear whether the rule’s estimated benefits justify the costs.
  • The proposed rule’s IRFA is deficient.
    • The supplemental IRFA should adequately estimate potential impacts to regulated small entities, including the relative impact of costs based on entity size.
    • The supplemental IRFA must include specific regulatory alternatives that would minimize the impact to small entities, and which accomplish the agency’s objectives.

For more information, please contact Meagan Singer, Assistant Chief Counsel at or (202) 921-4843.